Held that claim that the expenditure on account of annual exchange service charge was revenue expenditure could, by no stretch of imagination, be said to be ex facie bogus. Disallowance thereof could not lead to the conclusion that the assessee was guilty of furnishing of inaccurate particulars of income or concealment of income. The conduct of the assessee was not contumacious so as to warrant levy of penalty under section 271(1)(c) of the Act. (AY. 2011-12)